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`In the Matter of, )
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`CERTAIN ROBOTIC VACUUM CLEANING ) Inv.No. 337-TA-1057
`DEVICES AND COMPONENTS THEREOF )
`SUCH AS SPARE PARTS )
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` Hearing
` Honorable Thomas Pender, ALJ
` Monday, September 25, 2017, 9:01 a.m.
`
` US International Trade Commission
` 500 E Street SW
` Washington, DC
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`Silver Star Exhibit 1024
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`
` HEARING,
`pursuant to the Notice, before the Honorable Thomas Pender,
`Administrative Law Judge, taken by Marjorie Peters, RMR,
`CRR, Registered Merit Reporter, Certified Realtime Reporter
`and Notary Public in and for the District of Columbia, at
`US International Trade Commission, 500 E Street SW,
`Washington, DC, on Monday, September 25, 2017, at 9:01 a.m.
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`APPEARANCES:
`For the Complainant:
` Ruffin B. Cordell, Esquire
` Stephan Marshall, Esquire
` Linhong Zhang, Esquire
` Andrew Pearson, Esquire
` FISH & RICHARDSON, PC
` The McPherson Building
` 901 15th Street, NW, Suite 700
` Washington, DC 20006
` rbc@fr.com
` smarshall@fr.com
` lwzhang@fr.com
` apearson@fr.com
`
`For the Respondents Hoover; Royal Appliance Manufacturing
`Company, Inc., doing business as TTI; Floor Care North
`America, Inc.; the Black & Decker Corporation; Black &
`Decker U.S.A., Inc.; Bobsweep, Inc.; Bobsweep U.S.A.; and
`Shenzhen Silver Star Intelligent Technology Corporation:
` Jack Ko, Esquire
` PILLSBURY WINTHROP SHAW PITTMAN LLP
` Suite 4201, Bund Center
` 222 Yan An Road East
` Shanghai, 200002, People's Republic of China
` jack.ko@pillsburylaw.com
`
` Bryan Collins, Esquire
` Kecia Reynolds, Esquire
` Jack Borufka, Esquire
` William Atkins, Esquire
` PILLSBURY WINTHROP SHAW PITTMAN LLP
` 1650 Tysons Boulevard, 14th Floor
` McLean VA 22102-4856
` bryan.collins@pillsburylaw.com
` kecia.reynolds@pillsburylaw.com
` jack.borufka@pillsburylaw.com
` william.atkins@pillsburylaw.com
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` APPEARANCES:
` For the Respondents Bissell Homecare and Matsutek
` Enterprises, Co., Ltd.,:
`
` Harold Davis, Esquire
` K&L GATES
` 4 Embarcadero Center, Suite 1200
` San Francisco, CA 94111-5994
` harold.davis@klgates.com
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` For the Respondents Shenzhen ZhiYi:
`
` Nicholas A. Brown, Esquire
` GREENBERG TRAURIG
` Four Embarcadero Center, Suite 3000
` San Francisco, CA 4111
` brownn@gtlaw.com
`
` P.J. McCarthy, Esquire
` GREENBERG TRAURIG
` 2101 L Street, NW
` Suite 1000
` Washington, DC 20037
` mccarthyp@gtlaw.com
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` P R O C E E D I N G S
` JUDGE PENDER: All right. Everyone, please be
`seated.
` We're off the record.
`(Off the record.)
` JUDGE PENDER: This is investigation number
`337-TA-1057. It's the Markman hearing.
` The good thing is, let me say, I think I
`understand basically how these devices work. So, I don't
`know how much you need to go into the technology, tutorial,
`but we'll see.
` The normal rule -- I got a late start today
`because there was some paper that I had to think about, and
`because I wanted to think about what you all had done
`before I heard you talk about it as far as what you've
`agreed under the terms.
` We'll break for lunch today probably a quarter
`of 12:00, and we'll take a morning break, and we'll quit
`today at 4:45. I don't know whether we'll finish today or
`not, but we have tomorrow.
` Beverage is fine in the courtroom, provided
`they're in indestructible container or a bottle with a
`tight fitting lid. Please no styrofoam cups or
`Starbucks-like cups. Water bottle is fine. The official
`rule is no food. Anyway, the only part about that that I'm
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`adamant about is no gum.
` Although they tell me they're going to paint
`these places and replace the carpeting in them, keep your
`fingers crossed. I want to put on the record in at least
`one of my cases; and that is, I have been after them since
`I have been here to replace the chairs that you guys sit
`on. So now that we know, we have observed and we
`understand they're uncomfortable.
` Anyway, I remembered to turn my phone off before
`I put it in my pocket, which I'm going to check again, but
`please make sure, everyone, that yours is off as well, and
`anything that can make noise.
` All right. For appearances for claimant, I see
`Mr. Cordell. Who else do we have?
` MR. CORDELL: Yes, Your Honor. With me are my
`colleagues Steve Marshall, Linhong Zhang, Andrew Pearson,
`and let me introduce our clients. I have Tonya Drake who
`is the vice president and assistant general counsel of
`iRobot, and with her is her colleague Maya Choksi.
` JUDGE PENDER: Thank you very much, sir. And
`for respondents first.
` MS. REYNOLDS: Good morning, Your Honor. Kecia
`Reynolds from Pillsbury Winthrop Shaw Pittman; and with me
`are my colleagues Mr. Jack Ko, Mr. Bryan Collins, Mr. Jack
`Borufka, and Mr. Bill Atkins -- William Atkins. I'm sorry.
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` JUDGE PENDER: Were your representing more of,
`Black & Decker, et cetera.
` MS. REYNOLDS: Your Honor, we're representing
`Hoover; Royal Appliance Manufacturing Company, Inc., doing
`business as TTI; Floor Care North America, Inc.; the Black
`& Decker Corporation; Black & Decker U.S.A., Inc.;
`Bobsweep, Inc.; Bobsweep U.S.A.; and Shenzhen Silver Star
`Intelligent Technology Corporation.
` Your Honor, I would also like to have
`Mr. Borufka introduce the clients as well.
` MR. BORUFKA: For Pillsbury respondents Black &
`Decker, Jun Yun.
` We have for TTI Josh Grisson, and Bill Nabors,
`and for Silver Star we have Farrell Yang.
` JUDGE PENDER: All right. What's the next
`respondent.
` MR. DAVIS: Good morning, Your Honor. Harold
`Davis of K & L Gates. I'm here on behalf of Bissel and
`Matsutek.
` I'm here by myself except for my client
`representatives. I have William Brennan, who is the
`general counsel of Bissell. I have Tom Ankey, who is the
`patent counsel for Bissel; and then I have Dave Alexander,
`who is the vice president of sales for Matsutek.
` JUDGE PENDER: Okay. There's got to be another
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`respondent here. Who else?
` MR. MCCARTHY: Good morning, Your Honor. P.J.
`McCarthy on behalf of Shenzhen ZhiYi from Greenberg
`Traurig. With me today is Nick Brown and Tessa Mager.
` JUDGE PENDER: Okay. Anyone else that I have
`not taken an appearance from today.
` All right. Thank you. And if you haven't done
`so, please give your business card to the court reporter.
` Go ahead. I guess you're ready to start with
`the tutorial, Mr. Cordell. The thing that amazes me, all
`of this is probably seen on educational TV at one point or
`another when MIT graduates or when MIT freshmen get in
`there, they get into the robot fights.
` From what I understand, that's what led
`indirectly, if not even directly to this particular
`invention in the last, you know, few decades; is that
`correct?
` MR. CORDELL: That's exactly right, Your Honor.
`The founders of iRobot hail from MIT and they were robotics
`focussed while in college and then wanted to extend that
`work when they got out, and that's brought a myriad of
`developments that we'll take you through in a few moments.
` JUDGE PENDER: I admit to having been
`entertained by those things over the years.
` MR. CORDELL: I wonder why they don't weaponize
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`them.
` JUDGE PENDER: Oh, boy. They're bad enough
`bumping into furniture. Can you imagine if they weaponized
`them, too. We would not be safe for our children or
`grandchildren.
` MR. CORDELL: I promise you my son would talk of
`little else if that were available.
` Your Honor, the way we plan to do the tutorial,
`is I'm going to start with a few introductory comments and
`we were going to have our expert, Dr. Stephen Derby,
`actually pick up the ball and run with it and talk about
`some of the technology.
` So, if I could, could I have Dr. Derby take the
`stand?
` JUDGE PENDER: Go ahead.
` MR. CORDELL: While he's doing that, may I
`approach?
` JUDGE PENDER: You may, sir.
` MR. CORDELL: Always have to bring enough for
`everyone.
` Your Honor, one of the things that I neglected
`to do was to introduce the most important members of our
`team, Mr. Jeff Sayres and Mr. Patrick Edelin, who makes
`sure everything runs on time here.
` JUDGE PENDER: You usually introduce them
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`before.
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` MR. CORDELL: I can do without these guys. I
`can't do without them, that's for sure.
` So, may it please the Court.
` We are here for the technology tutorial in this
`investigation; and as Your Honor pointed out, Your Honor,
`we're very proud at iRobot at the history of robotics.
` The fact that our founders came from MIT and
`were looking for a way to extend the work they had done
`there in the private sector. There really wasn't anything.
`This was back in 1990.
` They wanted -- it was a passion. They wanted to
`bring robotics to life. Their focus originally was in the
`military arena. We'll talk a little bit about that, but
`then they began looking at consumer applications and had
`done some really marvelous things, and I'll touch on a few
`of those.
` Just as an overall agenda today, we're going to
`talk about background and I'll do a little bit of that.
` Then Dr. Derby will pick it up and talk about
`the specifics of the robotics technology at issue here, the
`sensors, the behaviors and exactly how those things are
`applied in the robotics context to solve real problems.
` So, what I have got on slide 4 are a bunch of
`the robots that iRobot has developed over the last, I guess
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`it's since 1990. In the upper left-hand corner, we see the
`Roomba, which is the consumer cleaning product that is
`going to be the focus of this case, but there are a number
`of different ones.
` Next to it is the Braava, which is a little bit
`like the Roomba, except that it's wet. It can mop your
`floors. Not only sweep and clean up, but can use water and
`detergent to mop.
` Next to that is the PackBot, which is one of the
`military robots that iRobot developed, and I'll talk a bit
`about that in a moment.
` That and with its twin down in the center of the
`screen, which is another PackBot, those have been used
`extensively by the U.S. military to save lives.
` Instead of sending troops down a cave or into a
`tunnel, the PackBot takes that job. They carry cameras,
`they can carry ordnance, they can carry all kinds of
`things, really to avoid putting U.S. service people in
`harm's way. Really a marvelous technology.
` The Ava is in the lower left-hand corner which
`is kind of a unique device. It's sort of a remote
`teleconferencing and interaction platform that allows, for
`example, a doctor who can't get to a remote site can
`actually interview patients using the Ava. It's got a
`screen. It's got telepresence.
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` So that Your Honor could, for example, use it to
`1
`not come downtown. You can have Ava sit in your chair.
` I'm not recommending that, but it would be
`possible. It's that -- that's the notion there, and it's
`usually used for people who can't get to a site who are
`critical to a particular situation.
` The Looj is something that I'm personally going
`to have to go out and get, which is the lower right-hand
`corner device. I have gutters that are very hard to get
`to, and this thing, you actually place it into your gutter,
`and then it will -- it will do the work for you at
`elevation, and you never have to get on a ladder. You
`never have to leave the ground.
` So, it's a way to clean your gutters remotely,
`which again is just personally is a remarkable development.
` You know, the iRobot's technology has been used
`to explore the Great Pyramids, to explore space, to clear
`subsea mines, really a myriad of applications; but the
`PackBot is one that iRobot is very proud of because it was
`really the first widely deployed military robot that the
`U.S. had -- really anybody in the world had.
` In 1998, iRobot won a DARPA contract really to
`build the PackBot, the first really general purposes
`tactical robot.
` In 2001, within 18 hours of the 9/11 attack
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`PackBots were on the ground helping personnel look for
`survivors and get through the wreckage safely and save
`lives.
` Then when the latest round of Gulf wars broke
`out, the PackBot was deployed widely, and there were myriad
`examples of the PackBot saving lives. Where before a squad
`member would have to put himself or herself in harm's way,
`the PackBot could do the work.
` It was tragic when one of them would get blown
`up or lose one, but not nearly what we would face if we
`lost a service member. So, it really became a widely
`deployed, widely used very valuable technology.
` In -- in the early 2000s, iRobot began to look
`for ways to take all of the technology they developed and
`turn it towards consumer applications.
` The idea was to take everything that we had
`learned about sensors and guidance and the ability to
`control these devices and put it in everybody's homes,
`really bring to fruition that vision that our MIT founders
`had way back in 1990.
` So, in 2002, the Roomba was launched, the Roomba
`being the consumer version of the robot that is relatively
`inexpensive and very accessible.
` I have one in my home that its primary duty is
`to keep after the dog which is a full-time job and it
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`really is a marvelous technology.
`1
` JUDGE PENDER: You know the double entendre in
`what you just said, right? Keep after the dog. How many
`dogs are not terrified of vacuum cleaners.
` MR. CORDELL: I will tell you, mine is. It's
`very entertaining, though, I have to admit. My wife would
`not like it if I said that on the record, but he is. The
`when the Roomba approaches, the dog is watching it
`constantly.
` JUDGE PENDER: Yes.
` MR. CORDELL: He probably really doesn't know
`what it is. You see videos of little dogs riding on them.
`I clearly don't have that dog.
` JUDGE PENDER: No.
` STEPHEN DERBY, PhD,.
`called as a witness, testified as follows:
` MR. CORDELL: With that, I'll turn it over to
`Dr. Derby and let him pick up the train. I may stay up
`here just in case there are clarifications I may want to
`ask.
` But with that, Dr. Derby, why don't you pick up
`the train.
` THE WITNESS: Thank you. Speaking of picking
`up, I want to pick up the robot here.
` JUDGE PENDER: See if that microphone is on so I
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`can hear you.
` MR. CORDELL: You know what, Your Honor, I
`neglected to introduce Dr. Derby.
` He is Professor Emeritus at RPI. He has been
`there for almost 40 years, including his years as a student
`there, has written dozens and dozens of papers dating back
`to the 1970s, holds 15 patents, is been a remarkable
`resource for the Rensselaer Polytechnical Institute, and
`his focus for his entire career has been on robotics.
` He's is a very valuable asset. We're happy to
`have him here. Dr. Derby.
` THE WITNESS: Thank you. The microphone is
`better? You can hear me now?
` JUDGE PENDER: A little better.
` THE WITNESS: When you put a vacuum cleaner in a
`home, it is not being operated by telepresence with
`somebody at a remote site. It's relying on its sensors to
`figure out what are the obstacles, how do I traverse
`safely. How do I clean the floor.
` So, the issues the issues are a little different
`than military. Of course, cost effective, energy
`efficient. You can't have a battery the size of your
`normal car battery.
` And also safety issues in terms of kids and
`dogs. You don't want anyone getting caught in a pinch
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`point.
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` JUDGE PENDER: Of course, the battery technology
`has taken off in the last five years like nobody's
`business.
` THE WITNESS: Yeah. The Lithium ion has really
`helped. It's really helped.
` So, the vacuum robot needs to have a
`microprocessor to basically create what are the control
`strategies. You can see the microprocessor in the large
`yellow rectangle, and the small yellow rectangles on the
`left are bump sensors, cliff sensors, wall sensors. We'll
`talk briefly about each of those.
` But it's to basically make sure that, as I have
`the Roomba right now on the edge of this desk, it is a --
`representing a stair. We don't want the vacuum to go off
`the deep end.
` So, if we watch this quick video, it is referred
`to as cliff sensing. It's showing the infrared technology
`of that the floor has disappeared, its cliff; and you need
`to change your direction.
`BY MR. CORDELL:
` Q So, what happens if it misses the cliff?
` A If it misses the cliff, it will fall down.
` Q I know they make these to be pretty rugged, but
`going down a set of stairs probably doesn't sound like a
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`great idea?
` A Not multiple times, at least.
` So, in order to do that, we use an infrared
`emitter and a photo detector.
` And the infrared emitter is like a cousin to
`your remote control for your cable box. Even though the
`video showed some red light being transmitted, you
`basically can't see what the infrared is showing.
` So, it has a constrained field where it is
`giving off the red infrared light, and then at an
`appropriate angle is a photo detector to detect in the
`defined area of intersection, is there something present in
`that red shape.
` And if there is something present, that will
`reflect back to the photo detector. Here we'll have our
`little obstacle for the demonstration that reflects, and
`then the sensor does trigger.
` So, in terms of the cliff sensor, we basically
`use this to sense the floor all the time; and if we have a
`floor reflecting into the photo detector, we know at least
`in this area of the behavior, that we're not at a cliff.
` So, we need to constantly be monitoring, and
`most robot vacuums have more than one of these cliff
`sensors to make sure in some type of motion you're not
`going off the deep end.
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` Here's a cliff itself, a stair. I don't have
`1
`any cliffs in my house. I have stairs. But the reflection
`is off the stair, which is inches lower, and therefore the
`photo detector does not sense anything.
` Q I guess when you're three inches tall, though, a
`stair looks like a cliff. I mean, robot's not that big.
` A Well, it's not a stair climbing robot.
` Here's yet another brief video of the actual
`operation of having a behavior to say we're getting right
`near the edge. Tipping a little bit, but can recover, and
`then change direction, keep cleaning.
` Q Let's talk about proximity sensors. Can you
`explain that to the Judge?
` A Take the same photo emitter and detector pair
`and turn it so that it's looking outwards. So, we can find
`out if we are approaching an obstacle -- could be a wall --
`and so the light beam infrared comes out in this pattern.
` We have the same area of interest. In this case
`here, the obstacle is going to move to the left
`effectively; basically, the robot's moved to the right.
` When it's in the region, the sensor detects it,
`and then it determines whether it should change direction
`or go into a different mode. But it allows it to know that
`you're at a wall, and at a specific distance.
` You can take the detector and rotate it
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`counter-clockwise if you want to basically modify the
`effective range of the sensor.
` So, if we rotate it as shown here, we can move
`the area of intersection outwards.
` And this is not something that the robot
`dynamically does in operation. It's something that the
`design engineers have as a parameter they can adjust of how
`close do they want to detect with the proximity sensor.
` Q You can decide how far away the proximity alarm
`will be triggered?
` A Yes. And then decide, well, if I want to keep
`it in a certain range, say for following a wall, then I
`know I what I can do.
` Q Tell us about bump sensors.
` A The bumper on the vacuum is different than the
`bumper on your car. The bumper on your car, you hope you
`don't come in contact with anything.
` The bumper on this basically is designed to
`purposely deflect, and something maybe about an eighth of
`an inch.
` So, that panel is connected up to a couple of
`sensors, and there's springs; and the thing will basically
`recenter itself when you pull away from after being bumped.
` If we look at the two sensors, the left bump
`sensor and the right bump sensor, and the timing of when
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`they're triggered, we can actually determine from the
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`timing difference where is the wall.
` In this case here it's about a 45-degree angle.
`The left bumper sensor would be triggered first, the right
`one second; and calculations can be done to define where
`that obstacle is.
` If we are, say, coming straight into the wall,
`both bump sensors would be triggered at the same time; or
`if we go to kind of skim the wall, the left bump sensor is
`triggered, and the right one not at all.
` Q Let's see one more. What are wheel sensors,
`wheel drop sensors?
` A The wheels are a required thing in terms of the
`motion of the wheels, and if someone were to pick up a
`vacuum cleaner while it's in operation, you've created a
`pinch point, an area where somebody can get hurt.
` So, the normal operation of the wheel is in the
`center picture where you can almost not see it at all.
` The right picture shows the fact that there's a
`arm that's holding the wheel with a spring and a sensor
`such that if you were to lift it up and put it upside-down
`like this, the wheels pop up. And then the system
`immediately shuts off.
` Q So, tell us a little bit about the command and
`control aspects of the Roomba.
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` A The command and control uses all of these
`sensors. On the left, the four cliff sensors, the two
`wheel drop sensors, the bumper with the integrated sensors,
`and the transparent paddle to the infrared light, and
`connecting to the microprocessor shown there to basically
`control the different modes of operation.
` Q So, tell us about the modes of the Roomba.
` A There are three basic modes here of how the
`vacuum cleaner can work:
` Spot-cleaning, when it actually senses that a
`high concentration of dirt is in a certain area. It can
`follow an obstacle, whether it's a bookshelf or a wall, or
`it can go into bounce mode.
` Look at all of them very briefly here.
` Spot-cleaning mode. Again, it's sensed that
`there's a lot of particles in a certain spot. It can move
`in a spiral, a square, hexagon, ellipse, some pattern.
` But if we look at the right, we see Figure 6A,
`it can move counter-clockwise in an outward spiral.
` 6B, we can go counter-clockwise to an inward
`spiral.
` And Figure 6C shows a reflective spiral that, as
`it's going through the process, when it hits an obstacle,
`Box 101, it will stop and reverse.
` You can't use spot cleaning all the time because
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`eventually, with wheel slippage, et cetera, you will start
`1
`having areas that are missing. Spot cleaning is only good
`for a certain region of interest.
` Q What is obstacle following?
` A Obstacle following is where you either follow a
`wall or, say, a bookshelf or something that's on the floor;
`and you use a proximity sensors to keep the robot at a
`fixed distance.
` That way, you can clean up to the edge of the
`wall with good results.
` Q You have video here. What's happening?
` A Well, the robot has already gone on the wall
`underneath the window and now it's turned so that it's
`following the bookshelf.
` Q What can you tell us about the distance that it
`maintains between the robot and the bookshelf?
` A Well, you can just judge visually that it's, at
`least from its visual inspection, it seems to be the same
`distance.
` Q Okay. What's bounce mode?
` A Bounce mode is where the object following and
`the spot cleaning don't cover everything; and so, it's a
`mode where you basically randomly move around to different
`spots to get complete coverage. It increases the
`efficiency when you use all three modes.
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` Q Let's talk about iRobot's Light Touch
`technology. Can you tell us what that is?
` A Yes, it's a combination of using the proximity
`sensors and the bumper.
` So, it basically, when the proximity sensor
`senses I'm getting close to an obstacle, I'll slow down,
`wait until I bump on purpose. That way I'm bumping at a
`slower speed, and then, depending on whether the bump
`sensor is triggered or not triggered, go into two different
`modes.
` Here we see the robot basically saying there's
`no obstacles, move to the left. Finds the obstacle, the
`wall. It slows down. And then, when the bumper hits, it
`causes the robot to move in a different direction.
` If the bump sensor is not triggered, the motors
`are directed to resume full speed.
` Next slide shows a video of that, of a
`comforter, cloth over on the couch. Since the bumper was
`never pushed in, it basically says, okay, it's a soft item.
`I can go underneath it and continue to clean underneath the
`couch and pick up speed.
` Q How would this have been different if that had
`been a wall instead of a soft comforter that it can push
`through?
` A If that had been a wall it would have been like
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`the animation before, where it would have come to a stop
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`and changed direction.
` Q Take us through some of the cleaning hardware
`used in iRobot's products.
` A Well, the sensors and the control system, the
`behavior algorithms need to do -- make something work.
` So we have multiple central brushes. We have
`extractors. We have rotating side brush.
` The side brush needs to basically cooperate with
`the main brushes in the vacuum system to basically push
`particles where it's going to pick it up.
` But importantly, the side brush cannot interfere
`with the cliff sensors. Here we're focusing in on one of
`the four cliff sensors.
` The fact that the side brush only takes up a
`small percentage of the rotation. It can't be a constant
`fat brush.
` Q Just to make sure the graphic is clear, what
`part of this is the cliff detector; what part of it?
` A The cliff detector is basically the
`black-and-gray type item. Right now, the -- one of the
`three brushes is partially covering it.
` Q Okay. So, this is a three-arm brush setup?
` A Yes.
` Q Okay.
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` A So, if we look at the cleaning hardware, we
`start in the upper left. We have the side brush moving
`particles that are up against the wall. The center top
`shows the two extractors basically agitating and lifting
`the particles so the vacuum can take place.
` The upper right shows the air flow that is
`taking those particles into the collector bin. It has a
`filter, and then the fan or the vacuum blows the exhaust
`out the side.
` The lower picture shows all three combined.
` Q So, the brushes move the dirt to the middle of
`the unit, the extractors pick it up, and then the suction
`takes it away; is that fair?
` A Correct.
` Q Okay.
` We have video. Can you tell us what's happening
`here?
` A We are having a photo from a, basically a glass
`floor. We're looking underneath. Normally what you can't
`see in your vacuum at home.
` It's taking the particles